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P. M. Bakashi, Comparative Law: Separation of Powers in
India, 42 A.B.A. J. 553 (1956).

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Comparative Law:

Separation of Powers in India

by P. M. Bakshi • of the Rajasthan Judicial Service (India)

* The first half of the twentieth century has seen the creation of literally dozens the legislative power shall be vested
of new constitutional governments. Americans should be flattered that our own in or shall exclusively reside in the
Constitution, the oldest national charter of government in the world, has influenced Parliament (see Articles 79 and
so many of the world's statesmen who are leading their own nations into prideful 245). Article 246 (1) does of course
self-government. Mr. Bakshi's article is an interesting comparison of some of the say that "Parliament has exclusive
common features of our Constitution and the new Constitution of India. power to make laws with respect to
any of the matters enumerated in
a The doctrine of separation of trol of the executive would, accord-, List I". But the words "exclusive
powers, as understood in the United ing to this doctrine, be completely power" in this clause are meant to
States of America, means that there beyond the sphere of the legislature. exclude the state legislatures and are
are three branches of the machinery Determination of disputes and adju- not intended to close the doors
of the state, each of which has its dication of questions of fact or law against the executive. Similarly, the
own functions, namely legislative, would also be beyond the sphere of articles relating to the judicial pow-,
executive and judicial; and that the legislature. er do not say that the judicial power
each branch must be strictly limited It may be noted here that even in of the Union shall be exclusively
to its own sphere and should not be the United States of America, where vested in the Supreme Court (see
allowed to trespass upon the sphere the doctrine of separation of powers Article 131 and the succeeding arti-
allotted to any other branch. A neat has been most vigorously canvassed, cles) . In Article 131, the words "to
statement of the doctrine is found it has not found favor in an abso- the exclusion of any other court"
in the Massachusetts Declaration of lute undiluted form. Intermingling are intended to exclude other courts;
Rights, 1780, as follows: of functions is, to a certain extent, they do not embody any mandate
inevitable, and has been accepted of the Constitution-makers that no
In the Government of this Com-
monwealth the legislative depart- even in the United States of Ameri- judicial function shall be conferred
ment shall never exercise the exec- ca. Now let us see how far the doc- upon the legislature or the execu-
utive and judicial powers, or either trine holds good under the Indian tive. Coming to the article relating
of them. The executive shall never Constitution. to the executive power (Article 53),
exercise the legislative and judicial
powers, or either of them. The judicial The first thing that strikes any per- one does meet the words "the exec-
shall never exercise the legislative and son who begins a study of the Indian •utive power of the Union shall be
executive powers, or either of them. Constitution from this point of view vested in the President and shall be
To the end it may be a Govern- is that there is no express declara- exercised by him either directly or
ment of laws and not of man. tion of the doctrine of separation of through officers subordinate to him
It follows that if the doctrine powers in the Indian Constitution. in accordance with this Constitu-
strictly applies, the legislature should No words have been used solemnly tion". But even here, one does not
never be allowed to assume judicial affirming or formulating the doc- find words like "exclusively". It
or executive functions. Powers of ap- trine in any particular article. The appears, therefore, that the constitu-
pointment and dismissal, supervision articles that relate to the legislative tion-makers did not consciously ap-
of the administrative set up and con- power, for example, do not say that prove of the philosophy of separa-

June, 1956 " VoL 42 553

Separation of Powers in India
tion of powers.
Secondly, an examination of the
detailed provisions of the Constitu-
tion also supports the view that it
was not the intention to lay down
anything like "prohibited areas" for
the three branches of the Govern-
ment. There is a liberal mixture of
functions of the one type with func-
tions of another type, as the follow-
ing analysis indicates:
I. The Legislature. (A) Executive
functions of the legislature. The leg-
islature exercises the following func-
tions which are essentially of an
executive nature:
(1) Voting in the election of the
President (Article 55) ;
(2) Voting in the election of the
Vice President, and his removal (Ar-
ticles 66 and 67);
(3) Control of the Council of
Ministers (Article 75, which says
that the Council shall be collectively
responsible to the House of the Peo-
ple)
(4) Removal of Judges of the Su-
preme Court and of the High Courts
(Articles 124 and 217);
(B) Judicialfunctions of the Leg-
islature. The legislature exercises
the following functions which are
essentially of a judicial nature:
(1) Impeachment of the Presi-
dent (Article 61) ;
(2) Certification of money bills
through the Speaker (Article 110);
(3) Judicial functions in connec-
tion with parliamentary privilege,
including committal for contempt
(Article 105).
II. The Executive. (A) Legisla-
tive functions of the Executive. The
Executive under the Indian Consti-
tution exercises the following func-
tions which are essentially of a legis-
lative nature:
(1) Power of the President to pro-
mulgate ordinances (Article 123);
(2) Power of the President to
make regulations for the peace and
good government of all territories
specified in Part D of the First Sched-
ule and any other territory com-
prised within the territory of India
but not specified in that Schedule
(Article 243) ;
(3) The President's veto (Article
554 American Bar Association journal
111);
(4) The President's power to is-
sue a proclamation of emergency
which has the effect of increasing the
field of legislative powers of Parlia-
ment (Article 352) ;
(5) The President's power to sus-
pend remedies for the enforcement
of fundamental rights (Article 359) ;
(6) The President's power to is-
sue a proclamation of failure of con-
stitutional machinery in the states,
which authorizes the Parliament to
assume the legislative powers for
that state-powers that can be dele-
gated to the President (Article 356) ;
(7) The President's power to rec-
ommend money bills, and to give
previous sanction to the bills to be
introduced in state legislatures that
might impose restrictions on the
freedom of trade and commerce or
intercourse with or within that state
(Articles 117 and 304) ;
(8) The President's power to cer-
tify state laws relating to eminent
domain (Article 31) ;
(9) The President's power to vali-
date the existing state laws relating
to taxes in respect of water or elec-
tricity stored or generated by inter-
state river development authorities
(Article 288) ;
(10) The President's power to de-
clare how far existing laws interfer-
ing with the freedom of trade, com-
merce and intercourse shall continue
(Article 305)
(11) The President's power to
make temporary provisions with re-
spect to Jammu and Kashmir and to
adapt existing laws in order to bring
them into accord with the Constitu-
tion (Articles 370 and 372);
(12) The President's power to pro-
rogue and dissolve the House of the
People and to summon both Houses
(Article 18) ;
(13) The President's power to as-
sent to the amendment of the Con-
stitution (Article 368).
(B) Judicial functions of the Ex--
ecutive. The Executive under the
Indian Constitution exercises the fol-
lowing judicial functions:
(1) Power of the President to
grant pardons and to suspend, remit
or commute sentences in certain
cases (Article 72);
(2) The President's power to de-
cide questions as to whether a mem-
ber of either House of Parliament
has become subject to any disquali-
fication for membership (Article
103).
III. The Judiciary. (A) Legisla-
tive powers of the Judiciary. At least
one of the functions of the judiciary
is legislative, namely, niaking rules
for regulating its practice and pro-
cedure (Article 145) ;
(B) Executive powers of the ju-
diciary. An example of this is the
power to appoint officers and serv-
ants of the High Court (Article 46).
The survey made above will show
that the Constitution does not pay
homage to the doctrine, either by
precept or by example.
It now remains to be seen whether
the doctrine would have any utility
in India. It is submitted that an ac-
tion of any branch of the state in
India cannot be declared invalid
merely because the quality of the
action is such that it belongs to an-
other branch. In other words, an act
of Parliament cannot be declared to
be void merely because it amounts
to adjudication provided it is other-
wise valid, and the same rule would
certainly apply to the judiciary. Con-
formity with the provisions of the
Constitution is of course necessary,
but conformity to the doctrine as
such is not necessary for the validity
of any measure.
The current of judicial authority
supports this view. Certain observa-
tions of Sir Patric Spens, C. J.,
in Piare Dusadh v. The Emperor
A.I.R. [1944] F. C. 1, 8, are some-
times cited in support of the view
that the doctrine is to be followed
in India. The observations are:
As a general proposition, it may
be true enough to say that the leg-
islative function belongs to the Leg-
islature and the judicial function to
the judiciary. Such differentiation
of functions and distribution of
powers are in a sense part of the
Indian law as of the American law.
But these observations should be
read along with the context. On the
same page of the report His Lord-
ship observes that "in India the Leg-

islature has more than once enacted
laws providing that suits which have
been dismissed on a particular view
of the law must be restored and re-
tried". And further: "In view of the
history of the rule in America, it is
questionable whether it would be
right to apply the same rule in this
country". The facts in this case be-
fore the Federal Court were that the
Special Criminal Courts Ordinance
(Ordinance 2 of 1942) having been
declared void in an earlier case by
the Federal Court, the Governor-
General had promulgated a new Or-
dinance (Ordinance 19 of 1943), by
Section 3 of which it was provided
that any sentence passed by the
courts acting under the old Ordi-
nance should have effect and should
continue to have effect as if the trial
had been held in accordance with
the Code of Criminal Procedure by
a court exercising competent juris-
diction under that Code. The valid-
ity of this section was challenged
before the Federal Court, on the
ground that it amounted to an exer-
cise of the judicial power. The main
argument on this point was that ac-
cording to the American authority,
legislative action cannot be, made to
retroact upon past controversy and
to reverse decisions. The Federal
Court expressly rejected this view
and held that it cannot be applied
in India. There are, of course, ob-
servations to the effect that the sec-
tion in question did not amount to
exercise of the judicial power, but it
is doubtful if the court would have
arrived at a different result even if
the sections had been found to be
an example of an exercise of the
judicial power.
In a Patna case, Bankey Singh v.
Jhingan Singh, A.I.R. [1952] Patna
166, a provision of a Bihar Act, de-
claring certain persons to have been
in possession as "Raiyats" of certain
lands on a particular date and pro-
hibiting suits to question such pos-
session and declaring decrees incon-
sistent with such possession to be
void, was held to be ineffective, on
the ground that "The State Legisla-
ture is not competent to reverse the
decisions and orders of the court...
because the power to nullify the de-
crees and orders of the court is pure-
ly a judicial power and the Constitu-
tion does not appear to have given
jurisdiction to the legislature either
expressly or by necessary intendment
to arrogate to itself the power to ad-
judicate-a power which is exclusive-
ly within the jurisdiction of the
court". Laxmi Kant Jha, C.J., relied
upon the observations of Spens, C.J.,
already quoted, and observed that
the power to reverse the decisions
of the courts is essentially judicial
and has not been conferred upon
the legislature by the Constitution.
His Lordship observed that though
there is no express definition of the
powers of the judiciary in the Con-
stitution, still "it is well settled that
when a department is created by the
Constitution for the exercise of judi-
cial authority, the Constitution con-
templates the whole judicial power
to be exercised by the Judicial
Department alone", A.I.R. [1952]
Patna 166, 173. It is respectfully sub-
mitted that this goes against the es-
tablished practice of the Indian
legislature, and there is no provision
in the Constitution which indicates
any intention to incorporate the doc-
trine of separation of powers. This
case has been expressly dissented
from in A.I.R. [1955] Patna 1,
where the court expressly rejected
the argument that the legislature
under our Constitution cannot over-
ride the effect of a judicial decision
(see page 31 of the Report). The
question involved there was of the
validity of the Bihar Land En-
croachment Act 1950 (Bihar Act 31
of 1950), which directed the Collec-
tor to evict any person unauthorized-
ly occupying any land which is a
public property. The argument of
the appellant was, that "the Act ad-
judicates and does not legislate".
Narain, J., while agreeing that there
was no scope left in the Act for judi-
cial determination by the Collector,
held that "if the Act is constitution-
ally valid and within the legislative
competence of the legislature and
not void on the ground of repug-
nancy, then, there being no positive
inhibition in our Constitution pre-
Separation of Powers in India
P. M. Bakshi is Draftsman in the Law
Department of the Government of Ra-
jasthan. He was graduated from the
Government College of Law at Bombay
(affiliated with Bombay University) at
the top of the list of successful exam-
inees and has practiced law in the Bom-
bay High Court. He was appointed
legal adviser to the Government of
Mewar and then to the Government of
Rajasthan.
venting the legislature from exercis-
ing judicial power, the Act cannot
be declared invalid, simply because
it is in effect adjudicating with re-
gard to the rights of the parties".
(The Act was, of course, held in-
valid in this case, not on the ground
of the doctrine of the separation of
powers, but on the ground that it
violated the fundamental right re-
lating to property).
There is one more case of the
Patna High Court, where Rama-
swami, J., expressed the opinion,
that "in India there is no doctrine
or dogma of separation of the vari-
ous powers. It is important to note
that our Constitution has not vested
the judicial power or the legislative
power in separate departments of
the State. The articles of our Consti-
tution do not divide and establish
areas of black and white", Ram
Prasadv. The State of Bihar, A.I.R.
[1952] Patna 195, 197. Sarju Prasad,
J., expressed no final opinion on this
point. This decision was reversed on
(Continued on page 594)
June, 1956 • Vol. 42 555
The Fifth Amendment
minority building on the historically incor-
rect views of the minority in Brown v. Walk-
er. Of course, there can be no question of the
correctness of the majority decision, even
though predicated on the erroneous historical
background of Counselman v. Hitchcock. Un-
der the correct historical view, the Fifth
Amendment never did apply to congressional
hearings; and so there could be no serious
constitutional question concerning the power
of Congress under the "necessary and proper"
clause, as a matter of grace, to adopt the Eng-
lish practice of granting immunity whenever
Congress is pursuing an appropriate consti-
tutional purpose.
It may be confidently predicted that law-
yers, both North and South, will lift their
eyebrows over the statement in the majority
decision in the Ullman case: "Nothing new
can be put into the Constitution except
through the amendatory process. Nothing old
can be taken out without the same process."
Close to the acme of judicial amendment
of the Constitution is the decision in Slochow-
er v. Board of Education, decided by the
United States Supreme Court on April 9, 1956,
in which, reversing the New York courts, it
was held that it was a violation of the due
process clause of the Fourteenth Amendment
for a New York City public institution of
higher learning to discharge a professor pur-
suant to an express provision of the New
York City Charter for having invoked the
Fifth Amendment before a congressional com-
mittee. Indeed, how outmoded was the think-
ing of the Founding Fathers when they limited
Separation of Powers in India
(Continued from page 555)
another ground by the Supreme
Court in Ram Prasad v. The State
of Bihar, A.I.R. [1953] Supreme
Court 215.
Legislation amounting to adjudi-
cation of a particular dispute may,
however, violate the guarantee of
equal protection of the laws and
equality before the law under Arti-
cles 14 and 15 of the Constitution,
and may be void on that account.
This is what happened in Ameerun-
nissa v. Mahboob Begum, A.I.R.
[1953] Supreme Court 91. The facts
of that case are interesting. On the
death of Nawab Waliuddowla, a
nobleman of the Hyderabad State,
disputes arose regarding succession
to his property, and, to put an end
to those disputes, an act known as
the Waliuddowla Succession Act of
1950 was passed by the Hyderabad
State, whereby the claims of succes-
sion put forward by Mahboob Be-
gum and Kadiran Begum, two of the
alleged widows of the late Nawab,
and their children, were dismissed.
These two ladies as well as their
children filed a petition before the
Hyderabad High Court under Arti-
cle 226 of the Constitution on the
ground that the Act was void under
Articles 14, 19 and 31 of the Consti-
tution. The High Court of Hydera-
594 American Bar Association journal
the privilege to "any criminal case"! Now,
notwithstanding Mr. Justice Holmes' famous
epigram, when still a Massachusetts judge, In
McAuliffe v. New Bedford, 155 Mass, 216, 220,
29 N. E. 517, that petitioner "has no consti-
tutional right to be a policeman" (cited as
late as 1946 in United Public Workers v.
Mitchell, 330 U.S. 75, 99), a person now appears
to have a constitutional right to be a teacher
although he violates a specific public regula-
tion conditioning his employment on not in-
voking the Fifth Amendment. See also the
excellent statement of Lassing J., in Scholl v.
Bell, 125 Ky. 750, 102 S. W. 248 (1907), quoted
approvingly by Wigmore, supra, §2251. There
was a time when the Court held that the ac-
tion of a state in prescribing the conditions
on which public work should be done suggest
only considerations of policy with which the
courts have no concern. Heim v. McCall, 239
U.S. 175 (1915); Stephenson v. Binford, 287
U.S. 251, 276.
What has happened to the Fifth Amendment
is the building of bad judicial precedent on
bad judicial precedent far away from the
words and the intent of the Founders. The
writer suggests the pertinence of the classic
statement that "a frequent recurrence to fun-
damental principles is essential to the per-
petuity of free government".
However, the present Supreme Court, in the
light of its general orientation, may perhaps
be expected to hold that the Court has so
often amended the Fifth Amendment and so
often decided against its true intent that it
cannot now return to first principles and to
bad accepted the petition and on
appeal the Supreme Court agreed
with the view of the Hyderabad
High Court that the Act was void
on the ground of violation of the
equality clause. It is strange that no
attack was made on the validity of
the Act on the ground of the doc-
trine of separation of powers, and it
seems that the counsel for the peti-
tioners did not think it worthwhile
to advance any argument in that di-
rection.
In, Ram Prasad v. The State of
Bihar, A.I.R.,[1953] Supreme Court
215, the Bihar Sathi Lands (Restora-
tion) Act 1950 (Bihar Act 34 of
1950), was held to be void on the
ground of violation of the equality
clause. The Act in question was
passed with the object of declar-
ing the settlement of certain lands
known as Sathi lands in the Cham-
paran district to be void and restor-
ing the lands in question to the
Bettiah Wards estate. The petition-
ers who had obtained possession
under the settlement challenged the
validity of the Act on the ground
that in passing the impugned legis-
lation the Bihar legislature actually
usurped the power of the judiciary
and the enactment was not a law at
all, and further, that the Act was
void as it conflicted with Articles 14
and 19 of the Constitution. The Su-
the clear and simple language of the Founding
Fathers. Still it must be conceded that fre-
quent affirmance of a constitutional construc-
tion has not deterred the Court when, without
even lip-service to stare decisis, it wills other-
wise. One notes a most recent instance in the
School Segregation Cases (discussed in April,
1956, issue of the JOURNAL) in which the Court
blandly brushed aside the unanimous decision
made in 1927, when, affirming the Supreme
Court of Mississippi in Gong Lure v. Rice, 275
U.S. 78, it ruled that the school segregation
involved was "the same question which has
been many times decided to be within the
constitutional power of the state legislature
to settle without the intervention of the feder-
al courts under the Federal Constitution"--the
unanimous Court being composed of Chief
Justice Taft and Justices Holmes, Brandeis,
Stone, Van DeVanter, McReynolds, Suther-
land, Butler, and Sanford. Speaking parenthet-
ically, shall we now expect further amend-
ment by the Court by the upsetting as "out-
moded" of the many century-old state laws
against mixed marriages, the prevention or
diminution of which is only one of numerous
completely rational bases for segregated
schools?
It can hardly be gainsaid that rewriting and
amending the Constitution in one's own im-
age, rather than seeking the intent of the
framers of its provisions, and requiring lawful
resort to the established amendment proce-
dure, seems to be the order of the day.
Certainly the Fifth Amendment has not es-
caped.
preme Court held the act to be void
on the ground that the legislature
had singled out two individuals and
denied them the right that every
Indian citizen possesses to have his
rights adjudicated upon by judicial
tribunals in accordance with law
which applied to his case. The court,
however, thought it unnecessary to
embark upon a discussion as to how
far the doctrine of separation of
powers applied in India and whether
the legislature can arrogate to itself
the powers of the judiciary and pro-
ceed to decide disputes between pri-
vate parties by making a declaration
of the rights of one against the other
(see A.I.R. [19531 Supreme Court
215, 219).
The conclusion that emerges from
this discussion is this:
I. The Indian Constitution does
not contain any formal declaration
of the doctrine of separation of pow-
ers.
2. The Indian Constitution, in its
actual provisions, does not exhibit,
any scrupulous regard for the doc-
trine of separation of powers.
3. Legislation in India cannot be
declared to be void merely on the
ground that it amounts to adjudica-
tion. The authority on this point is--
not very strong, but in principle this
appears to be the position.
4. Legislation amounting to adju-
 Separation of Powers in India

dication may, however, be held to be
void if it discriminates against any
person or group without justifica-
tion. This has been established con-
clusively by two decisions of the
Supreme Court. In practice it will
be difficult for the legislature to es-
cape successfully an attack on this
ground.
5. Legislation amounting to adju-
dication may further be held to be
void on the ground that it takes
away property without compensa-
tion or unreasonably restrains the
enjoyment of property; see Articles
19 and 31 of the Constitution. This
has not been decided by the Su-
preme Court, but is a fairly plausible
ground of attack.
6. An act of the legislature which
purports to confer on the executive
a wide legislative power may be held
to be void on the ground of an un-
due delegation of powers. This is
sometimes regarded as a branch of
the doctrine of separation of powers,
but it has to be kept separate.
7. If the executive assumes judi-
cial functions or is vested with judi-
cial function by any act, such an
assumption or vesting cannot be
void merely on the ground of the
doctrine of separation of powers,
though it is difficult to conceive of
many cases where the executive can
exercise the judicial function with-
out express legislation authorizing it
to do so. Such legislation would pre-
sumably be valid if it is otherwise in
accordance with the Constitution.
8. If the judiciary assumes legisla-
tive or executive functions, such an
assumption would be void, not on
any theoretical basis, but on the gen-
eral principle that a court cannot
exercise powers not conferred upon
it by law.

The Federal Courts mittee, a proposed resolution which Committee on the Administration of
in 1955 the Conference adopted, to author- the Criminal Law-Chief Judge
(Continued from page 552) ize the Chief Justice to appoint a John J. Parker, Chairman.
Committee on Judicial Statistics-
es notwithstanding the provision for panel of district judges, consisting Chief Judge Charles E. Clark,
discretionary jury trial made by of one or more from each circuit, to Chairman.
Rule 71A (h) of the Federal Rules study the special problems of pre- Committee on the Operation of *the
of Civil Procedure. trial in long complicated cases and jury System-Chief Judge Harry E.
to meet in conference for that pur- Watkins, Chairman.
The committee reported to the Committee on Bankruptcy Adminis-
Conference that a revised edition pose. The resolution contemplates
tration-Chief Judge Orie L. Phil-
of the handbook for petit jurors, that hereafter, in antitrust and sim- lips, Chairman.
which had previously been ap- ilar protracted litigation, one of the Committee on Pre-Trial Procedure-
proved by the Conference had been judges of this panel be made avail- Circuit Judge Alfred P. Murrah,
distributed throughout the judiciary able to the judge who will try the Chairman.
case, on his request, for consulta- Committee on Court Administration
for use in all the district courts. It Jr.,
tion and to sit jointly with him at -Chief Judge John Biggs,
also received a report on the cost of Chairman.
the operation of the jury system. pre-trial conferences.
The report of Chief Judge Reconstitution of Conference According to the report, the Con-
Charles E. Clark, of the Second Cir- Committees ference took a recess, subject to the
cuit, as Chairman of the Conference call of the Chief Justice, on Sep-
Finally, the Conference undertook tember 20, 1955.
Committee on Judicial Statistics,
a major reorganization of its com-
stated that during the spring of The Director's Report
mittee system, whereby all existing
1955, twenty-eight district court
committees were discharged and the The annual report of Henry P.
judges had co-operated with the
Chief Justice was authorized, with Chandler, the Director of the Ad-
Committee by keeping diaries for a
assistance from certain members of ministrative Office of the United
three-month period, of the amount
the Conference, to appoint, reap- States Courts, for the year ending
of time they spent in court and point, or reconstitute, such commit-
chambers on individual cases and tees as might seem appropriate. The June 30, 1955, dated September,
that this project had substantiated 1955, which had been presented to
report of the Chief Justice states the Judicial Conference at the open-
information obtained from previous
that under this authorization the ing of its September Session, in-
studies as to the relatively large
revised committee structure of the cludes a detailed report by the Di-
amount of judicial time required for Conference is as follows:
the disposition of private litigation vision of Procedural Studies and
Advisory Committee-Mr. Chief Jus- Statistics on the movement of cases
as opposed to cases in which the
tice Earl Warren, Chairman. and the nature of the judicial busi-
United States is a party. Committee on Supporting Personnel
-Chief Judge John Biggs, Jr., ness throughout the Federal Dis-
Pre-Trial Procedure Chairman. trict Courts, the Courts of Appeals
Circuit Judge Alfred P. Murrah, of Committee on Revision of the Laws and the Special Courts. This is sum-
of -Circuit Judge Albert B. Mars, marized in the report of the Chief
the Tenth Circuit, the Chairman Chairman.
the Conference Committee on Pre- Justice, supra. In addition, the Di-
Committee on Air Conditioning of
Trial Procedure, reported to the rector discusses a number of other
Court Quarters-Chief Judge John
Conference on behalf of his Corn- J. Parker, Chairman. aspects of the judicial business.

June, 1956 • Vol. 42 595